A cornerstone of the OBBBA is the implementation of mandatory Medicaid work requirements, set to go live in January 2027. This policy change will have serious consequences for Medicaid enrollees and those that serve them, costing millions of people, including community health center patients, their coverage. Exclusions and exemptions from the strict reporting mandate will be of central importance.
Writing in Health Affairs Forefront, Sara Rosenbaum, together with Jane Tavares and Marc Cohen at UMass – Boston’s The LTSS Center, and GW colleagues Alison Barkoff and Feygele Jacobs, looks closely at the “medically frail” exemption category in the statute, focusing on the subcategory “serious or complex medical condition.” In collaboration with GW and CHCs in Medicaid expansion states, whose patients will be especially vulnerable to losing coverage, the UMass researchers used data from the 2022 Health and Retirement Study (HRS) to develop a profile of older working-age adults who either do not work, or whose work is limited or sporadic. They found a substantial share had an identified, specific chronic medical condition, and further, that two-thirds have two or more conditions, while one-third have three or more conditions, adding to their health risk. This group was also more likely to use health services than their working counterparts.
As states work to develop their exemption processes, identifying these at-risk adults, and protecting their coverage and access, is essential.
Read: Implementing Medicaid Work Reporting Requirements: Defining A ‘Serious Or Complex Medical Condition’
Year-End Story You May Have Missed - Rural Impact Podcast
In the last Rural Impact Podcast episode of 2025, 'Uncertain Times for Community Health Centers,' Geiger Gibson Program Director Feygele Jacobs spoke with Michelle Rathman about the critical role of community health centers in the American healthcare system, especially in light of recent legislative changes such as HR1. They discussed the myriad challenges including funding cuts, Medicaid work requirements, and the impact of immigration policies on access to care. The conversation highlights the importance of CHCs in serving vulnerable populations and the potential consequences of policy changes on healthcare access and quality. Their discussion was followed by Michelle’s conversation with Joe Dunn, NACHC’s Chief Policy Officer, with more on the value of CHCs and essential investments needed in CHCs and workforce programs to sustain and grow the effective CHC community-based model of care.
Listen here: Uncertain Times for Community Health Centers with Dr. Feygele Jacobs and Joe Dunn